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    <title>2012 (10) TMI 127 - ITAT MUMBAI</title>
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    <description>Unutilized Modvat credit was required to be considered under section 145A for closing stock valuation, but the addition was set aside and the matter remanded for fresh verification. For section 80HHC, freight, insurance, packaging receipts and sales-tax set off or refund were excluded from business profits, though recomputation on net receipts was directed; foreign exchange gain from realization of export proceeds was held includible in business profits. Repairs and maintenance expenditure was sustained as capital in nature for want of evidence of a revenue character. The transfer pricing adjustment based only on a 10% discount was deleted, and development expenses paid to a non-resident were not disallowed under section 40(a)(i).</description>
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      <link>https://www.taxtmi.com/caselaws?id=217174</link>
      <description>Unutilized Modvat credit was required to be considered under section 145A for closing stock valuation, but the addition was set aside and the matter remanded for fresh verification. For section 80HHC, freight, insurance, packaging receipts and sales-tax set off or refund were excluded from business profits, though recomputation on net receipts was directed; foreign exchange gain from realization of export proceeds was held includible in business profits. Repairs and maintenance expenditure was sustained as capital in nature for want of evidence of a revenue character. The transfer pricing adjustment based only on a 10% discount was deleted, and development expenses paid to a non-resident were not disallowed under section 40(a)(i).</description>
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